Text For Citation: 02 Item/Group: 002 Hazard: ERGONOMIC

Section 5(a)(1) of the Occupational Safety and Health Act of 1970: The employer did not furnish employment and a place of employment which were free from recognized hazards that were causing or likely to cause death or serious physical harm to employees in that employees who sustained musculoskeletal disorders were exposed to increased risk of aggravation to existing injuries and illnesses and developing further injuries and illnesses: ITEM A - Where there were 678 cases of musculoskeletal disorders, of which 29 cases involved surgery, during the period of November 30, 1987 through February 13, 1990, and the medical management program was deficient in the following areas: 1) Lack of knowledge and instruction of management and production workers about the range of musculoskeletal disorders, means of prevention, causes, early symptoms or treatment of musculoskelal disorders. 2) Lack of a method of surveillance for, and early detection of, musculoskeletal disorders. 3) A philosophy on the part of management that the solution to the problem remains in self-selection of workers who are able to perform the job by terminating workers who develop hand or wrist pain or encouraging then to quit rather than eliminating or reducing the risk of musculoskeletal disorders through engineering or administrative controls. 4) The incentive that this produces for workers to not report symptoms. 5) Production quotas, pay incentives and management pressure that discourages reduced work rates for workers experiencing musculo- skeletal disorder symptoms. 6) Delaying diagnosis and treatment of workers with musculoskeletal disorder symptoms by three days as a matter of policy. 7) There was no tracking program (statistical ergonomic record) for monitoring musculoskeletal disorder trends. 8) Employees returned to their former jobs following medical treatment and time off for musculoskeletal disorders without the work environment having been modified to minimize the risk of reoccurences. In addition, there were no follow-up procedures to assess whether the employee's condition had changed. While ultimate responsibility for correcting the hazard rests with the employer given his superior knowledge of the operation, feasible, and acceptable abatement methods to correct this hazard include but are not limited to: 1) Implement a comprehensive written compliance program including priorities for early detection, treatment, job reassignment and follow-up of musculoskeletal disorders. The program shall include provisions for prompt recognition and evaluation of employee symptoms scheduling procedures for employees to help them recover from musculoskeletal disorders and surgery, and assurance of management's implementation of medical restrictions. This program shall be part of the overall written plan describing how and when each element will be accomplished. The overall plan shall be reviewed and updated quarterly to ensure goals are being met or to identify changes needed. 2) Implement a written program to identify employees developing musculoskeletal disorders, and work methods and work stations causing musculoskeletal disorders. a) Design a baseline symptoms survey to measure, on a plant-wide basis, the extent of employee awareness of their symptoms of work-related disorders. The results of which may be collected and processed by automated process. b) Conduct a plant-wide symptoms survey and repeat it annually to detect any significant change in the incidence, scope, and/or location of reported symptoms. This survey will also help to determine the effectiveness of the overall medical management program and employee job rotation program as related to ergonomics. c) Each quarter the employer shall review medical facility sign-in logs, OSHA-200 forms, and individual employees medical records to monitor musculoskeletal disorder trends in the plant. This analysis shall be completed in addition to the "symptoms survey" in order to monitor trends continuously and substantiate informatin obtained in the annual symptoms survey. d) Compile, and keep current, a written catalog of job activities for each work position. The activity performed at the work position should be described and stressors identified as they affect specific parts of the body such as: physical stress, forces required to exert, posture (twisting, turning, lifting, bending, misalignment of body parts), workstation hardware, repetitiveness of activity, lack of breaks, tool design, training employee turnover. A current catalog is very necessary to establish any "light duty" work positions and have an effective job rotation program. 3) Implement a written medical management protocol for musculoskeletal disorders. All physicians and nurses shall be qualified and trained to use this protocol which will include the following: a) A standardized physical examination, medical history and recording form. The examination will at least include inspection, palpation and range of motion testing and various applicable maneuvers, i.e., Tinel's test, Phalen's test, and Finkelstein's test. b) Specific protocols for the treatment of employees with positive physical signs on examination as well as those with symptoms but no physical signs shall be written and followed. Any symptoms with numbness or crepitus shall be referred to a physican. In addition, employees with positive Tinel's, Phalen's or Finkelstein's tests shall also be referred for physician evaluation. c) Schedule reevaluation in no more than three days after initial report of condition. If the condition worsens further, medical managment should be undertaken without concurrent efforts to reduce the physical stresses of the job by such measures as job modification or work practice changes, administrative changes, etc. A follow-up evaluation shall be scheduled in no more than three days, whether the condition is worsened or unchanged. d) A protocol will be directed by a physician and followed by management which will allow sufficient time for the involved muscle/tendon/nerve group to heal. This shall include time off work, or transfer to another job which allows the affected muscle/tendon/nerve group to rest. Employees shall be evaluated by a physician to assess their capability to return to work. Upon returning to work, they shall, when directed by a physician, be permitted to recondition the injured muscle/tendon/nerve group by gradual resumption of duties. This should occur in addition to any other prescribed treatments. 4) Develop and implement a training program for the medical staff to include a detailed review of the medical aspects of musculoskeletal disorders, and how to medically evaluate, treat, complete forms and reports, and to properly follow-up. The training shall include recognition of plant job-specific risk factors such as posture, force repetition, vibration, contact nerve pressure, and cold. The additive effect of risk factors for musculoskeletal disorders will be discussed along with an awareness of eliminating those which would aggravate the specific condtions of an employee. Medical personnel, including consultant physicians, will be informed as necessary as to the availability of restricted duty jobs appropriate for an employee with a specific condition. 5) Develop and implement a training program for all supervisors and employees to enable then to recognize early symptoms, the need for proper medical care, and the need to ensure work activities are compatible with employees physical conditions. 6) Conduct baseline surveillance. The purpose of baseline health surveillance is to establish a base against which changes in health status can be evaluated. Workers being assigned to positions involving exposure of a particular body part to repeated biomechanical stress will receive baseline health surveillance. These positions will be identified from the data compiled in the catalog of standard job descriptions. The baseline health surveillance will include a medical and occupational history, and physical examination of the musculoskeletal and nervous systems as they relate to musculoskeletal disorders. The examination should include inspection, palpation, range of motions (active, passice and resisted) and other petinent maneuvers of the upper extremities and back. Examples of the pertinent maneuvers for the hands and wrists include Tinel's test, Phalen's test, and Finkelstein's test. Laboratory tests, X-rays and other diagnostic procedures are not a routine part of the baseline assessment. 7) Analyze restricted duty jobs for musculoskeletal disorder potential. a) This written analysis shall include the procedures used in the performance of each job, including lifting requirements, postures, hand grips and frequency of repetitive motion. Such analysis shall be reduced to written form and provided to nurses, doctors, and supervisory personnel involved in the assignment of light duty jobs. b) When an employee in a job not previously evaluated reports a musculoskeletal disorder to medical personnel, that employee's actual performance of the job shall be evaluated to determine if ergonomic risk factors exist and corrective action is necessary for the work station and work method. 8) Develop a policy to inform employees that they will not be discriminated against because they reasonably request and visit the medical facilities or because they have diagnosed musculoskeletal disorder problems and are undergoing medical rehabilitation. ABATEMENT SCHEDULE STEP #1: First Quarter A) Submit to the Area Director a written compliance program and plan of action outlining a schedule for the implementation of this medical program to identify and control musculoskeletal disorders. Quarterly progress reports updating this program and plan will be submitted to the Area Director until final abatement. B) Design the baseline symptoms survey and complete catalog of job activities. C) Assure employee protection against discrimination. STEP #2: Second Quarter A) Conduct a symptoms survey to identify musculoskeletal disorders. B) Initiate quarterly records review to monitor musculoskeletal disorder trends. C) Implement a medical management protocol. D) Implement medical, supervisory and employee training. E) Initiate analysis of all restricted duty jobs. STEP #3: Third Quarter A) Initiate baseline health surveillance. B) Complete analysis or restricted duty jobs. STEP #4: Fourth Quarter A) Corrective action shall be completed by the implementation of all phases of this medical program.